United States v. Reyes-Santiago, No. 12-2372 (1st Cir. 2015)

Appellant was one of 110 defendants charged in a two-count indictment with drug and firearms offenses arising from a drug ring operating in Bayamon, Puerto Rico. Appellant, along with most of the other high-level members of the conspiracy, pled guilty pursuant to plea agreements. Appellant received the stiffest sentence on Count One, the drug count, of 360 months, while the sentences of Appellant’s co-defendants ranged from 78 months to 324 months. Appellant appealed, seeking resentencing on Count One. The First Circuit vacated the sentence and remanded, holding (1) the rationale offered by the district court for the substantial disparity between Appellant’s sentence and the sentences of Appellant’s co-defendants was unsupported by the record; and (2) resentencing was also necessary for Appellant’s violation of his conditions of supervised release.